THE PRACTICE OF POST-DEVELOPMENT

MONITORING IN ENVIRONMENTAL IMPACT

ASSESSMENT: CLAIMS AND EVIDENCES
BY
OKPARA UCHE THADDEUS
Department of Agricultural Economics, Uniersit! of "igeria
E#mail$ uc%e&purpose'!a%oo(co(u)
E*ECUT+,E SU--ARY
Follow-up, auditing, impact monitoring, compliance monitoring and post-
development monitoring are familiar to environmental assessment practitioners as
members of a family of terms that relate to the general concept of feedback in the
Environmental Impact Assessment EIA! system, and they are commonly used
interchangeably in literature" #he term post-development monitoring is adopted for this
study and it is conceptualised as the measurement of environmental variables during
pro$ect construction and operation to determine the changes which may have occurred as
a result of the pro$ect" %ost-development monitoring represents a crucial point in
assessing the predictive force of the EIA procedure and it is becoming widely accepted as
the most crucial element of any EIA system" &ost countries in developed and developing
nations now have some form of EIA monitoring systems" 'ountries like 'anada,
Australia and the (etherlands that have long traditions of EIA practice, have well
established legislative re)uirements for EIA monitoring" In *+, monitoring is self-
regulatory" In developing countries, monitoring practices are recent and not well
coordinated even though there are regulations in place" Information on monitoring is
meager, scattered and the lessons learnt from EIA e,perience not well documented and
shared amongst stakeholders especially in Ethiopia, -outh Africa and (igeria" .hile the
benefits and needs for monitoring are well documented, and the re)uirements spelt out,
there seem to be only few pro$ects that undergo monitoring in most of the ten countries
surveyed in this study" #he tasks and responsibility for monitoring are shared amongst
proponents, regulators and the public communities!" .hat each partner does and when,
are defined by each countries regulations" .hile developed countries boast of a robust
track record of public participation and openness in their monitoring activities, the
developing countries lack well designed process for involving the public and the parties
involved lack the re)uired training and character" #he study proposed some
recommendations which sum up to suggest that post-development monitoring can and
will succeed if national governments show high level commitment and make efforts to
build information e,change networks across borders"
.( +"TRODUCT+O"
.(. Bac)groun/ +nformation
%ost-development monitoring is
gradually becoming the most crucial
element of the EIA system &orrison-
-aunders et al", /001!" EIA practitioners
worldwide agree that impact monitoring
is one important practice through which
EIA can fulfill its potential to learn
from e,perience .ood, /000!" #he
practice connotes a comprehensive short
or long-term hindsight review of
development pro$ects that have
undergone assessment, received
approval and are under construction,
recently completed, fully operational or
about to be decommissioned 2arry,
3445!" &onitoring transforms EIA from
a one time pre-pro$ect predictive
e,ercise to a continual assessment of
impacts, thus closing the loop between
pre and post-decision analyses
-hepherd, 3445!"
&onitoring plays several key roles in the
EIA system" It provides feedback by
comparing the actual impacts of a
pro$ect with its predicted impacts
facilitates learning!, it improves pro$ect
outcomes through better adaptive pro$ect
management facilitates control! and it
enhances communication of
environmental performance facilitates
environmental information retrieval!
&orrison--aunders et al", /006!" .ith
the increasing recognition of the roles of
monitoring world wide, the era where
little attention is paid to the actual
/
effects of pro$ects after an EIA document
is completed is gradually fissling out"
-ystematic follow-up and feedback has
conferred on EIA the capacity to produce
real world environmental benefits Arts
et al", /003!"
In spite of its relevance, monitoring is
not yet a well established activity in
most countries" A number of
recognisable reasons are responsible for
this" Environmental monitoring data are
e,pensive and difficult to collect,
interpret and integrate with other sources
of data 'anter, 3447!" Also, monitoring
is time consuming and most pro$ect
proponents are not usually patient
enough to pay attention to assessing
baseline or future conditions -hepherd,
3445!" &onitoring agencies lack
guidance since e,isting regulations in
most countries do not provide clear
procedures for monitoring .ood,
/000!" In some regions like the *- and
'anada! impact monitoring is often
embroiled in fears of self-incrimination
between agencies and proponents
'arpenter, 3447!"
#hese challenges notwithstanding, the
practice of EIA post-development
monitoring is a key to the success of the
EIA process" #he practice embraces the
four elements of monitoring, evaluation,
management and communication Arts
et al", /003!" Its success in any country
will depend greatly upon the regulatory
and institutional arrangements that drive
it" 8ther factors that may likely affect
the practice are the approaches and
techni)ues adopted and the resources
finance and humans! available for
effective e,ecution &orrison--aunders
et al", /006!"
-tudies have shown that most developed
countries and over half of the middle
income countries in Africa, Asia and
-outh America have some form of
impact monitoring re)uirements, either
mandatory or voluntary 9eorge, /000:
;outhed, /004!" For some it might be a
provision more on paper than practice
like -outh Africa, Ethiopia, <ong +ong
and (igeria!" In some developed
countries like 'anada, the (etherlands
and Australia, impact monitoring is
already a legislative re)uirement
&orrison--aunders et al", /006!"
.(0 Aim of t%e Paper
6
#he aim of this paper is primarily to
critically review the practice of EIA
post-development monitoring in some
selected developed and developing
countries that have the monitoring
procedure operational in their EIA
system! with a view to assessing the
legislative re)uirements for the practice
and the individuals involved in
monitoring"
0( POST#DE,E1OP-E"T
-O"+TOR+"2 +"
PRACT+CE$ 1E2+S1AT+,E
RE3U+RE-E"TS
0(. Oerie4
.hile the benefits and needs for impact
monitoring are well documented and
replete in literature, the actual means of
implementing it are lacking: which is
why a country may have laid-out
legislative re)uirements for monitoring
but few pro$ects would actually be
followed-up Arts et al., /003!"
<owever, having regulations or
legislative re)uirements in place is an
important first step in initiating EIA
monitoring of pro$ects during the
construction and operation phases"
Across the different countries that have
introduced EIA follow-up, four distinct
approaches in setting up regulations
have been observed" #hese are= 3! the
traditional command and control
approach where legislative influence is
paramount (igeria and -outh Africa are
e,ample!, /! the self regulation
approach where the commitment of the
proponents is paramount like in *+ and
to an e,tent Australia!, and 6! the
public pressure approach where the
drive to meet the demands of the public
or communities enforces follow-up
'arpenter, 3447: &orrison--aunders,
/006!" <aving some formal regulations
helps make follow-up or monitoring a
more structured and systematic e,ercise
in practice"
0(0 Reie4 of impact monitoring
re5uirements in some selecte/
Countries
>iterature shows that the content and
)uality of the regulations vary greatly
from country to country 9eorge, /000:
.ood, /000: +engne, /004: ;outhed,
/004!" E,periences and country goals
are known to influence prevailing
regulation" 2ased on available
information in literature, a review of
legislative re)uirements for impact
monitoring in <ong +ong, %ortugal,
'anada, the (etherlands, *+, '?ech
@
Aepublic and Australia will suffice here"
#hese countries are developed and have
long tradition of EIA practice"
Hong Kong= Impacts prediction and
derivation of mitigation measures
characterised <ong +ongBs early
approach to EIA" In 3440, an
Environmental &onitoring and Audit
E&CA! Aegulatory -ystem was
introduced and later amended in 3445 by
an EIA 8rdinance to make it a statutory
re)uirement and ensure effectiveness
and accountability in EIA practice Arts,
et al., /003!" According to <ui /000!,
the ma$or re)uirements set by the
E&CA regulation are that proponents
must compulsorily secure environmental
permits binding legal documents! for
construction, operation andDor
decommissioning, and that they must
employ Independent Environmental
'hecker IE'! to check works carried
out and the data collected by
environmental teams in charge of actual
monitoring and audit of work done on
sites" #he IE' also verifies and certifies
that mitigation measures are fully and
correctly e,ecuted according to
recommendations in the EIA report" #he
re)uirements are binding for all impact
monitoring activities Arts, et al., /003!"
Cana/a= #he 'anadian Environmental
Assessment Act called the Act! of 344/
clearly recogni?ed the relevance of post-
development monitoring in the EIA
process" #he Act specifies the approach
and ob$ectives for monitoring and allows
responsible authorities to design and
implement impact monitoring (oble
and -torey, /00@!" According to the
'anadian Environmental Assessment
Agency 'EAA, /004!, the re)uirements
specified by the Act are mainly about
predictive accuracy to verify the
accuracy of the environmental
assessment of a pro$ect! and
effectiveness of mitigation measures to
determine the effectiveness of any
measures taken to mitigate the adverse
environmental effects of a pro$ect!: and
it recommends e,plicitly that the results
obtained from the follow-up or
monitoring process be used to improve
the )uality of environmental
assessments, help ensure environmental
protection and promote sustainable
development" #he legislative
re)uirements for monitoring are
mandatory for monitoring activities and
E
they depart from what obtains in
Australia and the *+ Ahammed et al.,
/00E!"
8ne of the criticisms about the 'anadian
regulation is that it is reactive and not
proactive, meaning that it is not
e,plicitly ob$ective-oriented since
neither EA generally nor impact
monitoring specifically are designed to
sit within a planning and policy
framework 'EAA, /004!" Analysts say
the scope should be e,tended to cover all
areas of sustainable development, not
$ust on the biophysical environment
(oble and -torey, /00@!"
Portugal= According to Fesus /000!, the
new EIA regulations for %ortugal came
into force in /000, containing well
defined specifications for the EIA post-
evaluation phase" #he targets are to
ensure full compliance of pro$ects with
EIA decisions and enforce monitoring
and auditing in all cases" #o ensure
compliance, the regulations made it
legally binding on all proponents to
submit to competent EIA authority an
impact assessment compliance report
together with detailed pro$ect
proposals!, showing that the pro$ect was
developed in compliance with the
original EIA decision and that all the
proposed mitigation measures were
accommodated in the design Arts et al",
/003!" .ith the establishment of
monitoring programmes, proponents are
also mandated to submit monitoring
reports periodically to the authority" #he
new regulations empower EIA authority
to perform audits and verify compliance
of all aspects of construction, operation
or decommissioning of pro$ects with the
original EIA decision and ensure that
monitoring programmes are properly
implemented Fesus, /000!"
T%e "et%erlan/s= #he EIA regulations
introduced in the (etherlands in 3451
contained the mandatory re)uirements
for pro$ects evaluation" #he
specifications were legally backed by
Gutch Environmental &anagement Act
&ei$er and van Hliet, /000!" #he
regulations empowered the competent
EIA authority to approve pro$ect
decisions, provide evaluation
programmes and define what need to be
done at each monitoring stage and when"
#he authority does all the environmental
impact investigations during and after
pro$ect implementation" #he proponents
7
are re)uired to cooperate and follow the
decisions of the authority" Arts 3445!
however observed that in actual practice
it is the proponent that does the real
monitoring" #he regulations in place are
mandatory and thorough, but they have
not helped to fully establish EIA impact
monitoring practices" Han >amoen and
Arts /00/! reports that out of some 500
EIA approved pro$ects only 70 have
undergone impact monitoring as at /00/"
Unite/ King/om= Ae)uirement for
post-development monitoring is absent
in the *+ EIA regulations because of
effective EIA planning and
implementation procedures in place, and
the good practices of developers
2oyden, /00/!" #he Environmental
&anagement -ystems in place allows for
voluntarism and self-regulation and
these have been useful in driving the *+
EIA impact monitoring activities
&orrison--aunders et al", /006!"
&arshall et al. /003! provided instances
where industry-led initiatives have
played a useful role in follow-up
activities in *+" #his practice shows
how self-regulation or voluntarism may
be utili?ed to make up for deficiencies in
government regulation for EIA post-
development monitoring"
C6ec% Repu7lic= Ae)uirements for
monitoring of post-pro$ect impacts in
'?echBs EIA system are backed up by
the EIA Act of 344/ amended in /003!"
According to 2ranis et al" /00@!, the
re)uirements specified that developers
should conduct impact monitoring of all
pro$ects submitted for approval by
ensuring accurate data collection on
various environmental factors during
preparation, implementation and
operation phases of pro$ects" #he
&inistry of Environment and the Gistrict
Environmental 8ffices are main
regulators" #he re)uirements are
mandatory for all proponents but the
shortfall in the '?ech monitoring
process is that the Act does not provide
any practical background for monitoring
activities: there is no effective
institutional, personal and financial
support in place to impose the laid down
re)uirements 2ranis et al", /00@!"
Australia= &onitoring is considered as
one of the weakest areas in the EIA
system in Australia despite government
EIA regulations for monitoring
1
contained in the Australian
intergovernmental agreement on the
environment of 344/ which specify that
EIA process would provide a basis for
setting environmental conditions and
establishing monitoring, management
and review programmes 'onacher et
al", /000: Ahammed et al", /00E!" #he
legislative re)uirement here is largely
discretionary making the approach
similarity to that of the *+ <arvey,
3445!" In most Australian EIA
$urisdiction were there are no legislative
re)uirements like -outh Australia and
(ew -outh .ales! monitoring is
restricted only to licence conditions
Ahammed et al", /00E!"
0(8 +ssues in Deeloping Countries
&ost of the literature on EIA post-
development monitoring has emerged
from developed countries with a long
tradition of involvement in EIA
activities" Few literature on EIA practice
in developing countries show that impact
monitoring as part of the EIA system is
still at its infancy, information on
follow-up is meager and scattered, and
lessons learnt from e,perience are not
well documented and shared amongst
partners 8
B
2eime et al", /000: ;onas,
/000: Gayo et al", /00/, +engne, /004!"
#hese authors identified the following
issues as limiting factors to the practice
of impact monitoring in developing
countries= 3! limited capacity of
authorities to undertake EIA follow-up,
/! poor regulatory and procedural
framework and 6! issues concerning
human health and well-being AIG- and
malaria inhibit workersB productivity!" A
review of regulatory re)uirements for
monitoring in three developing countries
will suffice here"
Et%iopia= #he first comprehensive
statement of Environmental %olicy
covering all aspects of the EIA process
was approved in 3441 E%A, 3441!"
Among other issues, the policy specified
the need for regular and accurate
assessment and monitoring of
environmental conditions and to ensure
that EIA considers not only physical and
biophysical impacts but also all aspects
of sustainable development" It also
specified that public consultations
should be an integral part of EIA follow-
up process and that the process should
allow for an independent review and
public comments before consideration
by decision makers ;onas, /000!" #he
5
follow-up re)uirements apply mostly to
pro$ects whose location, nature or scale
makes them very likely to have
significant impacts on the environment"
;onas /00/! reported that the Ethiopian
EIA system still has little e,perience
with initiating and completing impact
monitoring of developmental pro$ects"
EIA follow-up legal documents are
being enforced to help the system"
Sout% Africa= %ost-decision follow-up
re)uirements were included as
conditions for pro$ect approval in the
new -outh African EIA regulations
promulgated in /007 -andham et al",
/001!" #he re)uirements are made
mandatory for all impact monitoring
activities but because the processes
involved are not well laid out,
enforcement has been weak ;outhed,
/004!" #he level of compliance among
developers is reportedly lower than
anticipated"
"igeria= Ae)uirements for impact
monitoring in (igeria have been in place
before /006 but they are relatively not
well observed even though they are
mandatory for all large EIA pro$ects"
Gayo et al" /00/! found that only about
60I of approved pro$ects were
monitored by the countryBs regulatory
agency" >ack of political will has kept
monitory in a slow transitory pace"
8( -O"+TOR+"2 TASKS A"D
RESPO"S+B+1+T+ES
#he task and responsibility for post-
development monitoring are usually
dependent on specifications in the EIA
follow-up regulations and also on the
type of pro$ect to be monitored" #hree
groups of stakeholders are usually
involved in monitoring tasks" #hese are
the proponent initiator or developer!,
the regulator conductor! and the
community participants! &orrison-
-aunders, et al., /006!"
Impact monitoring programmes driven
by proponents are often self-regulatory
or based on voluntarism or industry-led
initiatives as evident in Environmental
&anagement -ystems &orrison-
-aunders et al", /001!" In the *+ this
practice is greatly entrenched" <owever
when impact monitoring is driven by the
regulators, the focus is typically on
ensuring that proponents comply with all
EIA decisions as well as learning from
e,perience to improve the EIA system
4
.ood, /000!" Impact monitoring may
also be initiated by communities
concerned about environmental impacts
in their neighbourhood" -ometimes
agencies may be established to oversee
or conduct monitoring through
independent actions where they act as
Jenvironmental watch dogsB and help
promote two-way communication
between partners as evident in 'anada,
<ong +ong and %ortugal <ui, /000:
Fesus, /000!"
In most developed countries like
'anada, '?ech and the (etherlands!,
depending on the type of pro$ect,
government agencies and proponents are
usually re)uired to carry out monitoring"
In 'anada, for instance, proponents are
usually reluctant in the case of socio-
economic monitoring (oble and -torey,
/00@: 'EAA, /004!" 9enerally,
proponents will not always want to
engage in impact monitoring that appear
to be beyond their control or outside
their mandate, not minding the potential
financial benefits" <owever, the
prevailing EIA decision re)uirement for
these countries is that proponents have to
undertake impact monitoring or follow-
up as a condition for pro$ect approval 8
B
2eime et al", /000: 'EAA, /004!"
In Australia, developers are re)uired to
carry out pro$ectsB impact monitoring
under planned consent conditions or the
legal environmental permit system as a
make-up for the weak legislative
regulations in place Ahammed et al",
/00E!"
In <ong +ong, public participation in
the EIA monitoring process is greatly
encouraged, though the E%G and
proponents are more involved in the
actual field monitoring practice Arts et
al", /003!" &onitoring information is
usually made public to those interested
especially via E%G website" <ui /000!
reported that sometimes web-cameras
are installed on buildingDconstruction
sites to transmit real-time monitoring
activities" #his is a big merit to the
process since democratic participation in
monitoring encourages far reaching
cooperate efforts needed for success in
environmental performance"
In %ortugal, proponents and the EIA
authorities do most of the monitoring"
.hile proponents do the field work and
30
present reports, the competent
authorities verify accuracy of
compliance to EIA decisions and make
informed $udgments Arts, et al", /003!"
&onitoring and audit reports are usually
made public" Individual citi?ens and
(98s are allowed to raise complaints
about the environmental impacts of
pro$ects" 'omplaints are handled by
competent authorities Fesus, /000!"
In Ethiopia, -outh Africa and (igeria
African countries! competent
authorities like the environmental
protection agencies at the federal and
regional levels! along side developers
and other stakeholders are involved in
the EIA monitoring process" E,isting
regulations specified that the pro$ect
proponents developers! should be
responsible for undertaking monitoring
e,aminations to determine compliance
with EI- while competent authorities do
the final verifications >i, /005!"
&onitoring is still at its very infancy in
these countries"
&( CO"C1UD+"2 ASSESS-E"T
A"D RECO--E"DAT+O"S
&(. Conclu/ing Assessment
Gifferent legislative re)uirements for
monitoring are in place in the developed
and developing countries e,amined,
e,cept in the *+ where monitoring is
largely self-regulatory" .hile the
re)uirements are discretionary in
Australia and *+, they are largely
mandatory in others and legally binding
on the proponents" A comparison of the
developed and developing countries
reveals that the latter tend to include a
standard set of components in their EIA
systems that facilitate implementation"
#he developed countries have a robust
track record of public participation in
impact monitoring, meaningful
consideration of alternatives and also
consideration of cumulative impacts"
#his is especially the case with 'anada,
Australia and the (etherlands who are
reputed to have the strongest EIA
procedures"
In developing countries especially
Africa! impact monitoring practices are
recent and there is so much political
la,ity to enforce the legislative
re)uirements in place" #he monitoring
re)uirements do not clearly specify and
e,plain what work is needed and who is
responsible for what, and little attention
33
is given to accountability and
commitment of parties involved"
Finally, the review of the monitoring
re)uirements in all the countries shows
that there seems to be so much focus on
better biophysical environmental
performance than the broader issue of
sustainable development" -ocial,
economic and other human
environmental effects are not addressed"
It was the sustainability agenda that
birthed the EIA process and any EIA
monitoring regulation or procedure that
fails to connect with aspects of
sustainability will not be helping the
broad developmental agenda"
&(0 Recommen/ations
Impact monitoring has been identified as
a veritable incentive for improving the
)uality of environmental management of
pro$ects" #o make the process more
effective, there will be need to employ
the following recommendations=
i" legislative re)uirements should be
robust enough to e,plain in clear terms
what needs to be done, by who and
when, and should target meeting the
goals of sustainable development,
ii" attention should be given to clear and
accountable commitments of parties
involved especially in developing
countries,
iii" )uality can be improved through the
establishment of e,ternal independent!
bodies to take over the reviewing of
monitoring programmes and results $ust
as 'anada has done,
iv" openness, continuous reporting and
public participation can strengthen
impact monitoring and help address
concerns like uncertainty, sensitivity and
feasibility: information technology
should be $udiciously utilised to create
new opportunities for public
involvement in the process $ust as <ong
+ong has done,
v" training and capacity building is
re)uired mostly for developing countries
that have little e,perience: creating
information e,change network will
facilitate learning"
3/
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'ameroon %ipeline %ro$ect" 8nline material, available at http=DDwww"iaia"
8rgDiaia04ghanaDdocumentsDcsDcs/-EK(gouanaKEnvironmentalKcomplainceKand
Kmonitoring"pdf" Accessed on 3@D/D/030"
1i, ? ;0<<A!" EIA in Geveloping 'ountries= An 8pportunity for 9reater Environmental
-ecurity" .orking %aper (umber @: Foundation for Environmental -ecurity and
-ustainability"
-ars%all, R(, Smit%, " an/ Erig%t, R ;0<<.>( A (ew 'hallenge for Industry=
Integrating EIA within 8perational E&-" %aper presented at IAIA /003 EIA Follow-*p
8utcome and Improvement .orkshop, /7 &ay-3 Fune, 'artagena, 'olumbia"
3@
-eiCer, ? an/ an ,liet, ? ;0<<<!" EIA Evaluation= Added Halue by -creening and
-coping" %aper presented at the IAIA /000 2ack to the Future 'onference, EIA Follow-
*p -tream, <ong +ong 'onvention and E,hibition 'entre, 34-/6 Fune, <ong +ong"
-orrison#Saun/ers, A(, Ba)er, ? an/ Arts, ? ;0<<8>( >essons from the %ractice=
#owards -uccessful Follow-*p" Impact Assessment and %ro$ect Appraisal Fournal, Hol"
/3, (o" 3" 2eech #ree %ublishing, -urrey, *+"
-orrison#Saun/ers, A(, -ars%all, R an/ Arts, ? ;0<<D>( EIA Follow-*p= International
2est %ractice %rinciples" -pecial %ublication -eries (o" 7, Fargo, *-A= International
Association for Impact Assessment IAIA!"
"o7le, B an/ Store!, K ;0<<&>( #owards Increasing the *tility of Follow-*p in
'anadian EIA" Environmental Impact Assessment Aeview //= 376-350"
O
F
Beime, S(, Clar), - an/ Pree6, ? ;0<<<>( EIA Follow-*p= %erspectives on a
2urgeoining Aluminium Industry in two Geveloping 'ountries" %aper presented at the
IAIA /000 2ack to the Future 'onference, EIA Follow-*p -tream, <ong +ong
'onvention and E,hibition 'entre, 34-/6 Fune, <ong +ong"
San/%am, 1 an/ Retief, 9 ;0<<D>( EIA Follow-*p for Filling -tations in the (orth-west
%rovince of -outh Africa" Available online at
http=DDwww""docstoc"comDdocsD357EE44/DEIA-follow-up-for-filling-stations-in-the-(orth-
west-province-of-south-Africa" Accessed on 3ED/D/030"
S%ep%er/, A ;.@@A!" %ost-%ro$ect Impact Assessment and &onitoring" In %orter, A and
Fittipaidi eds" Environmental &ethod Aeview= Ae-#ooling the Impact Assessment for the
(ew 'entury" Available online at http=DD www"iaia"orgDpublicdocumentsDspecial-
publictionsD9reenI/02ookKEnvironment
I/0&ethodsI/0Aeview"pdf pages 6@-@E!" Accessed on 3@D/D/030"
,an 1amoen, 9 an/ Arts, ? ;0<<0>( EIA Follow-*p for Aoad %ro$ects= .hat do we want
and need to doL %aper presented at IAIABs /00/ Follow-*p .orkshop, 3E-/3 Fune, the
<ague, (etherlands"
Eoo/, 2 ;0<<<>( Is .hat ;ou -ee .hat ;ou 9etL %ost-development Auditing of
&ethods used for predicting the ?one of visual influence in EIA" Environmental Impact
Assessment Aeview /0 /000! E61-EE7"
3E
Yonas, T ;0<<<>( 'urrent -tatus of EIA -ystem in Ethiopia= EIA -tudy and Follow-*p"
In &c'abe, & and -adler, 2 eds"! -tudies of EIA %ractice in Geveloping 'ountries" A
-upplement to the *(E% #raining Aesource &anual, *(E% %ublications, /000= page
604"
Yout%e/, ? ;0<<@!" Assessment and &anaging the %otential for 'ompliance Gefault of
Applications -ubmitted in terms of -outh AfricaBs Environmental Impact Assessment
Aegulations" *npublished %hG #hesis, *niversity of -outh Africa Gepartment of
9eography!= pages 4- 11"
37